Since President Trump issued Executive Order (“E.O.”) 14275, “Restoring Common Sense to Federal Procurement” on April 15, 2025 as part of an effort to remake Federal procurement, the Administration has undertaken a variety of initial steps to implement its so-called “Revolutionary FAR Overhaul” (“RFO”). These steps include “streamlining” each Part of the Federal Acquisition Regulation (“FAR”) on a rolling basis to remove “non-statutory requirements.” To date, seven streamlined FAR Parts have been released on the RFO page of acquisition.gov: Parts 1, Federal Acquisition Regulation; 10, Market Research; 11, Describing Agency Needs; 18, Emergency Acquisitions; 34, Major System Acquisition; 39, Acquisition of Information and Communication Technology; and 43, Contract Modifications. The public has the opportunity to provide “informal input” for each Part—the soonest of which is to provide feedback on FAR Part 10 by July 7, 2025 at 4:30 PM ET.[1] Although the volume of streamlined FAR Parts, non-regulatory resources, and commentary on acquisition.gov has started to proliferate in recent weeks, the extent to which these resources can and will be relied on in a strategic, accessible manner by the broader acquisition community still remains to be seen.
GSA Seeks to “Operationalize” Streamlined FAR Parts While Maintaining Contracting Officer Discretion
As detailed in our previous post, the FAR Council and the Office of Federal Procurement Policy (“OFPP”) within the Office of Management and Budget (“OMB”) are in the process of issuing the streamlined FAR Parts through model deviations issued by the FAR Council and adopted by agencies accordingly. During a recent Industry Webinar, the General Services Administration (“GSA”) reaffirmed that formal notice-and-comment rulemaking will occur after all 53 FAR Parts have been revised. However, GSA stated that agencies will seek to “operationalize” the “interim deviations prior to rule-making.” This indicates that solicitations will contain these deviations, and existing contracts may be modified while rulemaking is pending.[2] GSA explained that agencies are required to adopt the FAR Council’s model deviation text, absent FAR Council approval of an agency’s modified text, unless the modified version “is necessary to address agency-specific statutory direction.” [3] Notwithstanding these points, contracting officers may continue to rely on the policies and practices removed from the FAR to the extent that the contracting officer deems them beneficial, which will encourage “contracting officer discretion in determining whether a practice is suitable rather than a matter of compliance.”[4]
During its recent industry webinar, GSA predicted that for administrative efficiency reasons contracting officers likely would not proactively modify existing contracts to implement the proposed, streamlined FAR Parts. However, contractors may affirmatively suggest (and indeed were seemingly encouraged to suggest) revisions to their existing contracts consistent with reducing burdensome requirements—especially where such revisions will provide cost-savings to the Federal government.
RFO Seeks to “Keep the Best of the FAR” and Move Other Content to Non-Regulatory Resources
In its webinar presentation, GSA elaborated on the RFO’s goal to “Keep the Best of the FAR,” which will include steps to:
- “[S]trip out non-statutory requirements” from the FAR
- Create “[o]ne central location for the acquisition community”
- Establish “[c]ommon clauses and representations” and “[a] common vocabulary to enable effective communication”
- Create “[a] shared rulebook” for Federal acquisitions
Although the RFO will streamline the FAR text, the removed content will not necessarily disappear entirely. Instead, the FAR Council and OFPP will be releasing “Non-regulatory Resources,” which will contain at least some of the excised material after review.
GSA has described the three types of new non-regulatory resources as follows:
- Practitioner Albums: “Curated learning tools for each FAR deviation”
- FAR Companion Guide: “A reference to operationalize the revised FAR”
- Category Buying Guide: “A tool to align purchases with category management principles”
To date, only Practitioner Albums have been made available on the RFO website, with Albums released for each of the streamlined FAR Parts that have been posted. The Practitioner Albums each contain a Change Summary and a Line Out document,[5] with further resources varying by Part. For instance, “Practitioner’s Perspectives” are provided from GSA or DOGE officials for some Parts.[6] These Practitioner’s Perspectives reflect shared themes of, among other things, aiding the Federal acquisition workforce in implementing the model deviations in their day-to-day operations, maintaining flexibility in procurements, and prioritizing efficiency.
Additionally, “Smart Accelerators”—described as “practitioner-inspired knowledge nuggets”—are also being made available. As an example, the Smart Accelerators corresponding to revised FAR Part 18 are meant to “enable faster procurements under FAR [P]art 18 emergency situations,” although the resource explains that “[t]hese practices are not limited to emergency acquisitions and can be used anytime!” The Smart Accelerators for FAR Part 39 focus on “[a]ccelerating the way we buy and deploy information and communication technologies,” and are meant to “promote faster acquisition and secure deployment of information and communication technologies, including information technology (IT), operational technology, emerging technology, and information systems.” Examples of the proposed FAR Companion Guide and Category Buying Guide are forthcoming.
The RFO website also has a page dedicated to “Frequently Asked Questions,” which captures some of the prior guidance provided in other forms. For example:
- Buying guides will be released over time, although no particular timeline has been provided.
- Agencies are expected to adopt the model deviations, though there may be exceptions for statutory or other extenuating reasons. (Thus far, however, the RFO website reflects varying levels of adoption of the model deviations among agencies, which are accessible at the “Agency Deviations” link within each “overhauled” FAR Part here.)
- Once all model deviations have been issued, formal notice-and-comment rulemaking will begin, which will “consider” the feedback provided during the overhaul process.
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To date, the RFO has overhauled seven FAR Parts in approximately two months, leaving 46 Parts remaining. As the overhaul process continues, contractors should carefully analyze the applicability of legacy FAR provisions and new deviations, as well as the extent to which contracting officers may exercise discretion within any given procurement or contract. Covington’s Government Contracts team is tracking developments in this rapidly evolving procurement landscape.
[1] As of the date of this blog post, the feedback deadlines for FAR Part 18, Part 39, and Part 43 are July 28, 2025 at 4:30 PM ET; and the feedback deadline for FAR Part 11 is August 4, 2025 at 4:30 PM ET. The latest deadline to submit feedback thus far is September 30, 2025 at 4:30 PM ET for Part 1 and Part 34. Some of these deadlines have been adjusted since their original posting, so it is possible there may be other changes.
[2] “From Policy to Practice,” Slide 27.
[3] See RFO – Frequently Asked Questions (last accessed on June 20, 2025) (Answer in response to: “Are agencies required to adopt the model deviation text?” and “Can agencies modify the model deviation text before adopting it?”).
[4] Id. (Answer in response to: “If policies and practices are removed from the FAR but the contracting officer finds their use is beneficial, should they continue using them?”).
[5] Per acquisition.gov, the Line Out document is not a crosswalk between the codified FAR Part and the proposed new language; rather, it reflects only the language that has been struck from the codified FAR Part.
[6] See, e.g., FAR Part 1 Practitioner’s Perspective, Commentary on the Revolutionary FAR Overhaul, by GSA Senior Procurement Executive Jeff Koses; FAR Part 10 Practitioner’s Perspective, Value of Industry Days & Forms-Based RFIs, by GSA Associate Administrator of Government-Wide Policy and Chief Acquisition Officer Larry Allen and Senior Procurement Executive Jeff Koses; FAR Part 39 Practitioner’s Perspective, Transition-Ready: Future-Proofing Government Technology by Avoiding Vendor Lock-in, by DOGE Director of Procurement Frank McNally.